Babcock-Hitachi v. Babcock-Hitachi
REITERATIONFacts
The Antecedents: Petitioner, Babcock-Hitachi (Phils.), Inc., planned to transfer its Design Department from Makati City to Bauan, Batangas. Consequently, three employees (Justiniano G. Iniego, Xavier Aguila, and Bonifacio B. Vergara) were notified of their re-assignment and transfer effective April 1, 1999. These employees claimed their relocation allowance as provided in the collective bargaining agreement (CBA). Procedural History: Petitioner refused to grant the allowance, citing a company policy statement (Policy Statement No. BHPI-G-044A) which stated that employees residing in Bauan or adjacent towns and permanently assigned back to the Bauan Plant were not entitled to relocation allowance. The respondent union filed a complaint for payment of relocation allowance. The parties submitted the case for voluntary arbitration, and the Voluntary Arbitrator ruled in favor of the employees. Petitioner's motion for reconsideration was denied. Petitioner then filed a petition for review with the Court of Appeals, which affirmed the Voluntary Arbitrator's decision. Petitioner's motion for reconsideration with the Court of Appeals was also denied. The Petition: Petitioner filed a petition for review on certiorari with the Supreme Court, assailing the Court of Appeals' decision, arguing that the appellate court erred in relying solely on the CBA and disregarding the company policy statement.
Issue(s)
Whether the affected employees are entitled to relocation allowance under the CBA despite the company's policy statement. Whether the Court of Appeals erred in affirming the Voluntary Arbitrator's Decision.
Ruling
The petition is DENIED. The assailed Decision dated May 14, 2002 and Resolution dated November 26, 2002 rendered by the Court of Appeals in CA-G.R. SP No. 65260 are AFFIRMED.
Ratio Decidendi
On whether the affected employees are entitled to relocation allowance under the CBA despite the company's policy statement: The Supreme Court held that the affected employees are entitled to the relocation allowance. The Court emphasized that any doubt or ambiguity in a contract between management and union members should be resolved in favor of the latter, pursuant to Article 1702 of the Civil Code. The provisions of the CBA regarding relocation allowance were clear and unequivocal: employees transferred from Makati to Bauan were entitled to ₱1,500.00 monthly, provided the transfer was permanent or exceeded one month. The Court reiterated the principle that the terms and conditions of a CBA constitute the law between the parties, and those entitled to its benefits can invoke its provisions. Furthermore, the Court found that the policy statement invoked by the petitioner was not part of the CBA and therefore could not prevail over the explicit terms of the agreement. The CBA, being the law between the parties, governs their relationship, and a unilateral policy statement contrary to its provisions cannot be sustained. The Court also noted that the new CBA superseded any prior policy statements that were not incorporated into the agreement. On whether the Court of Appeals erred in affirming the Voluntary Arbitrator's Decision: The Supreme Court found no error in the Court of Appeals' decision. The appellate court correctly affirmed the Voluntary Arbitrator's ruling, which was based on a proper interpretation of the CBA and applicable labor law principles. The Court of Appeals' reasoning that the workingman's welfare should be the primordial consideration in interpreting labor laws and contracts, including CBAs, was sound. The appellate court correctly distinguished between the binding force of a CBA and a unilateral company policy statement, holding that the latter cannot diminish the rights granted under the former. The Supreme Court concluded that the Court of Appeals did not commit any error as its assailed Decision and Resolution were consistent with law and jurisprudence.
Main Doctrine
A company policy statement that is not part of a Collective Bargaining Agreement (CBA) cannot prevail over the clear and unequivocal provisions of the CBA, which constitutes the law between the parties. Doubts in labor contracts are resolved in favor of the laborer.